For organisations operating in regulated sectors – financial services, healthcare, legal, energy and others – manager training is not simply a matter of employment law compliance.
Manager training sits at the intersection of sector-specific regulatory requirements, general employment obligations under PIDA and the Worker Protection Act 2023, and the evidential expectations of multiple regulatory audiences. Getting the approach right requires understanding what each layer demands and how to build a training programme that satisfies all of them.
The regulatory layer on top of employment law
All UK employers face the same baseline obligations for manager training under PIDA, the Worker Protection Act 2023, and the ACAS codes of practice. Regulated industries carry an additional layer of sector-specific requirements that can be more prescriptive, carry their own enforcement consequences, and are assessed by regulators operating independently of employment tribunals.
The interaction between these layers matters for training design. A financial services firm whose managers receive training aligned to PIDA but not to FCA conduct standards has addressed only part of its obligation. An NHS trust whose managers understand the ACAS disciplinary code but have not been trained on the duty of candour framework faces a similar gap. Regulated organisations need a training architecture that maps to all relevant frameworks, not just the most visible one.
Financial services: FCA conduct standards and non-financial misconduct
The Financial Conduct Authority’s Senior Managers and Certification Regime (SM&CR) places explicit responsibilities on senior managers for the conduct of those within their area of responsibility, including in respect of how concerns are received and escalated. The FCA’s non-financial misconduct rules (PS25/23), finalised in December 2025 and in force from 1 September 2026, go further – explicitly including how firms handle internal disclosures, bullying, harassment and discrimination within the conduct assessment framework.
For managers in FCA-regulated firms, this means:
- Training on whistleblowing and protected disclosures is not merely an employment law matter – it is a conduct matter that affects personal regulatory status
- Mishandling a harassment or whistleblowing disclosure can trigger FCA conduct consequences including withdrawal of approval, financial penalties and public censure, in addition to tribunal exposure
- Documented training is part of the evidence base a firm would need to produce in a regulatory investigation or supervisory visit
The FCA’s approach reflects a broader regulatory expectation that firms’ internal culture – including how managers respond to concerns – is a front-line conduct issue, not just an HR matter.
Healthcare: duty of candour and speaking-up frameworks
In healthcare, the statutory duty of candour (under the Health and Social Care Act 2008 and the Duty of Candour Regulations 2014) requires providers registered with the Care Quality Commission to be open and transparent with patients when things go wrong. The CQC assesses speaking-up culture as part of its Well-led inspection domain, and NHS organisations are required to have Freedom to Speak Up Guardians in place.
Manager training in healthcare settings needs to address both the general whistleblowing framework under PIDA and the sector-specific duty of candour and Freedom to Speak Up requirements. Managers who conflate or confuse these frameworks – treating a patient safety concern raised through a Freedom to Speak Up channel as a standard grievance, for example – create both regulatory and employment law risk.
Legal and professional services: SRA and regulatory conduct obligations
Solicitors regulated by the Solicitors Regulation Authority are subject to the SRA Standards and Regulations, which include obligations to report serious misconduct by colleagues. Law firm managers who receive a report of potential misconduct face obligations both as employers under PIDA and as regulated professionals under the SRA framework. Training that addresses only one dimension is incomplete.
The SRA has been increasingly active on bullying, harassment and speak-up culture within law firms, and its enforcement approach treats culture as a firm-wide regulatory matter. Manager training on handling disclosures – including the confidentiality requirements, the prohibition on retaliation, and the escalation pathways – is therefore both an employment law and a regulatory compliance requirement for regulated legal practices.
ECCTA and failure to prevent fraud: the cross-sector obligation
The Economic Crime and Corporate Transparency Act 2023’s failure to prevent fraud offence, in force from 1 September 2025, applies across sectors to large organisations meeting the Companies Act size thresholds. The adequacy of fraud prevention procedures – including whether organisations have functional internal reporting channels and trained managers to receive fraud-related concerns – is a direct element of the statutory defence.
For regulated organisations, this creates a converging obligation. A financial services firm, healthcare provider or professional services organisation that already has sector-specific requirements around internal reporting now has an additional ECCTA overlay. ACFE research from 2024 found that 43% of frauds are detected by tips from employees – making trained, trusted managers a key component of fraud prevention procedures across all regulated sectors.
Building a training architecture that meets multiple frameworks
Regulated organisations approaching manager training design should work through the following:
Map the frameworks that apply
Start by identifying which regulatory frameworks apply to the organisation and its managers – sector regulator requirements, general employment law obligations, and any international frameworks where operations span jurisdictions. This mapping exercise should be updated following major legislative changes: the past 18 months have seen ERA 2025, the WPA 2023 positive duty, ECCTA, and the FCA’s PS25/23 all come into force or be finalised.
Identify the gaps in existing training
Audit current training content against the mapped frameworks. Common gaps in regulated industries include: training that covers PIDA but not sector-specific reporting obligations; training that pre-dates the Worker Protection Act 2023 positive duty; and training that addresses harassment awareness without covering the whistleblowing protections that ERA 2025 attaches to harassment disclosures. Outdated content creates false assurance and weakens evidential defences.
Calibrate to the highest standard
Where multiple frameworks apply, design training to meet the most demanding standard. Training that satisfies FCA conduct expectations and PS25/23 requirements will typically also satisfy the PIDA and Worker Protection Act baseline. Training calibrated only to the employment law floor may leave regulatory gaps that are harder to defend.
Ensure training is accredited and documented
CPD-accredited training carries an independent quality marker that regulators recognise. The CPD Certification Service accredits courses against standards of accuracy, relevance and fitness for purpose – a quality assurance layer that generic internal training lacks. Documentation showing who was trained, on what accredited content, when and how training has been refreshed is the primary evidence base for both tribunal proceedings and regulatory review.
Related resources
Legal Obligations for Manager Training in the UK (hub): https://www.safecall.co.uk/resource/legal-obligations-for-manager-training-in-the-uk/
How does CPD-accredited training support legal defensibility: https://www.safecall.co.uk/resource/how-does-cpd-accredited-training-support-legal-defensibility/
Whistleblowing Training for Managers: https://www.safecall.co.uk/service/whistleblowing-training-for-managers-online-and-on-site/
Choosing a Workplace Training Provider: https://www.safecall.co.uk/resource/how-should-regulated-industries-approach-mandatory-manager-training/
Safecall’s training for regulated organisations
Safecall has delivered whistleblowing and workplace training since 1999 across a wide range of regulated sectors, including financial services, healthcare, legal and professional services. Its CPD Certified facilitated courses – Listen Up (Whistleblowing for Managers), Tackling Sexual Harassment – A Guide for Managers, Investigations Training and Investigative Interview Training – can be tailored to address sector-specific regulatory requirements alongside the general employment law framework. Safecall is part of Law Debenture Corporation, a FTSE 250 company, providing the organisational stability regulated clients require.
Find out more about Safecall’s training courses at safecall.co.uk/service/compliance-training/ or contact the team at learning@safecall.co.uk | +44 (0) 191 516 7720
Sources and further reading
FCA Policy Statement PS25/23 – Non-financial misconduct: fca.org.uk/publications/policy-statements/ps25-23-diversity-inclusion-non-financial-misconduct
FCA – Senior Managers and Certification Regime: fca.org.uk/firms/senior-managers-certification-regime
Care Quality Commission – Duty of candour guidance: cqc.org.uk/guidance-providers/regulations/regulation-20-duty-candour
NHS England – Freedom to Speak Up: england.nhs.uk/ourwork/freedom-to-speak-up/
Solicitors Regulation Authority – Standards and Regulations: sra.org.uk/solicitors/standards-regulations/
Economic Crime and Corporate Transparency Act 2023 – failure to prevent fraud guidance: gov.uk/government/publications/economic-crime-and-corporate-transparency-act-2023-factsheets
ACFE Report to the Nations 2024: acfe.com/report-to-the-nations/2024
Public Interest Disclosure Act 1998 (as amended): legislation.gov.uk/ukpga/1998/23